FDA premarket cybersecurity submission services aligned to the FDA February 2026 final guidance and Section 524B.
The cybersecurity section is the #1 cause of acceptance-checklist holds on premarket submissions. We return a fixed-fee quote within 24 hours of the discovery call so you know exactly what's missing before you submit.
Every artifact the FDA expects in a premarket cybersecurity submission - SPDF, SBOM with VEX, threat model, penetration test report, and Section 524B attestation - delivered eSTAR-ready by a senior US-based team. Aligned to the FDA February 2026 final premarket cybersecurity guidance. 250+ FDA submissions supported, zero cybersecurity rejections.
eSTAR-ready premarket cybersecurity sections
Section 524B(b)(1)-(3) documentation
SBOM (SPDX or CycloneDX) with VEX statements
STRIDE threat model + security risk assessment
Penetration test report (device, cloud, wireless, mobile)
Cybersecurity labeling + customer security guide
Not sure which package fits? Compare in 10 seconds:
Free 30-min call · Senior US expert · Mutual NDA before the call
FDA submissions supported
250+
Cybersecurity rejections
0
Quote turnaround
24 hrs
Last updated
“Blue Goat Cyber takes the burden off our engineers and makes FDA cybersecurity requirements easy to understand. Their expertise and smooth process mean we can focus on our pro…”
Amy Lynn, Chief Compliance Officer, Medivis
Trusted by medical device teams worldwide
Lifecycle scope
What's in your premarket cybersecurity package
Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.
01
FDA 2026 final guidance aligned
Built to the February 2026 final premarket cybersecurity guidance. Every artifact maps to the section the FDA reviewer is looking for.
02
eSTAR-ready attachments
Drops directly into eSTAR for 510(k), De Novo, and PMA submissions - no reformatting, no missing attachments, no acceptance-checklist surprises.
03
Secure Product Development Framework
SPDF integrated into your QMSR (21 CFR 820) and ISO 13485 processes with full traceability from requirement to verification evidence.
04
SBOM + VEX
Machine-readable SPDX or CycloneDX SBOM with NTIA minimum elements (now stewarded by CISA), support-end dates, and a VEX statement for every CVE in your shipping configuration.
05
Threat model + risk assessment
End-to-end STRIDE threat model with multi-patient harm, updateability, and use-environment views. Aligned to AAMI TIR57 and ANSI/AAMI SW96.
06
Unlimited revisions included
Fixed fee. Retests and revisions are included until the cybersecurity portion of your submission is closed. No per-cycle invoices.
Common FDA findings
The premarket cybersecurity gaps reviewers cite most
These are the issues showing up in real FDA acceptance-checklist holds and cybersecurity deficiency letters under the February 2026 final guidance.
Missing Section 524B(b)(1) postmarket plan
Premarket package lacks a vulnerability monitoring + coordinated vulnerability disclosure plan. Required for every cyber device.
SBOM without VEX statements
Bare SBOM ships with unresolved CVEs and no exploitability analysis. Reviewer requires VEX for every applicable vulnerability.
Threat model without traceability
STRIDE entries exist but no mapping to mitigations, test evidence, or residual risk. Reviewer requests full SW96 / TIR57 traceability matrix.
Pen test missed the full attack surface
Device firmware tested but cloud backend, mobile companion, and wireless interfaces skipped. Reviewer requires every interface in scope.
SPDF written as standalone doc
Secure Product Development Framework not integrated into existing QMSR / ISO 13485 design controls. Reviewer flags missing traceability.
No reasonable-assurance narrative
Artifacts ship without a narrative tying threat model, controls, and test evidence into a defensible reasonable-assurance conclusion.
Blue Goat Cyber vs. the alternatives
What you actually get versus a generic 510(k) consultant or building the cybersecurity package in-house.
Capability
Blue Goat Cyber
Generic 510(k) consultant
In-house
Mapped to FDA February 2026 final guidance + 524B
Section-by-section, reviewer-format
Legacy template, often out of date
Built from scratch each submission
SPDF + threat model + SBOM + VEX
All deliverables, one team
Outsourced piecemeal across vendors
Multiple internal owners, gaps emerge
FDA submission track record
250+ submissions, zero cyber rejections
Limited cyber-specific experience
First-submission risk
Pricing model
Fixed fee, unlimited revisions until accepted
Hourly + change orders
Hidden internal cost
Mutual NDA before first call
Standard, signed day 0
Usually after SOW
n/a
FDA Feb 2026 Guidance · §524B · eSTAR v7.0
Every premarket cybersecurity deliverable. Mapped to the eSTAR slot it lives in
What happens after you book the call
1Day 0
Mutual NDA + 30-min premarket scoping
We sign a mutual NDA, then walk your device, submission type, and the cybersecurity evidence the FDA reviewer will expect.
2Day 1
Point-by-point gap list + fixed-fee quote
Point-by-point gap list against Section 524B and the FDA February 2026 final guidance, each gap mapped to the artifact that closes it, with a fixed-fee quote covering every deliverable.
3Weeks 2-8
eSTAR-ready premarket cyber package
SPDF, SBOM with VEX, threat model, pen test report, and cybersecurity labeling - delivered in eSTAR-attachable format, reviewer-ready.
"Blue Goat Cyber takes the burden off our engineers and makes FDA cybersecurity requirements easy to understand. Their expertise and smooth process mean we can focus on our product, not the paperwork. The organized documentation, perfectly formatted for eSTAR, saves us countless hours."
- Amy Lynn, Chief Compliance Officer, Medivis
Cybersecurity deficiency remediation included
If the FDA raises a cybersecurity deficiency, we fix it at no additional cost. 250+ FDA submissions, zero cybersecurity rejections to date.
Mutual NDA before the call
We sign a mutual NDA before the initial call so you can share device details, architecture, and FDA correspondence freely.
Fixed-fee quote within 24 hours of the call
No sales pressure. After the call, you get a concrete written strategy mapped to Section 524B and the FDA February 2026 final guidance.
Senior US engineers, fixed fee
Senior-led delivery on every FDA-facing artifact. No offshoring, no hourly billing. Unlimited revisions. Every artifact is eSTAR-ready.
Common questions
Who you're talking to
Christian Espinosa, Founder & CEO
MBA, CISSP · U.S. Air Force Academy graduate · 30+ years in cybersecurity
Christian leads the senior medical device cybersecurity team behind 250+ FDA submissions, zero cybersecurity rejections. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.
30 minutes with a senior medical device cybersecurity engineer. Mutual NDA signed before the call. No pitch - we'll tell you straight if you don't need us.